The editorial "Rail Safety Since the Wreck" {Jan. 23} correctly cited the critical need for improvements to existing railroad safety laws and regulations. However, it overlooked the need for an incentive factor through the imposition of stiffer penalties on carriers found to be in violation of safety statutes.

Drug testing and "punishing" train crews fall short because these solutions fail to produce long-term improvements in the overall safety programs of railroads and wrongly ignore the deeper problem. Railroad workers already face one of the most dangerous working environments in the United States, and thus rail unions have argued all along that existing laws must mandate better on-site safety programs by carriers and responsible enforcement practices by the Federal Railroad Administration.

It is common practice for the FRA to duly note a blatant safety violation by a carrier. But in spite of the severity of a violation, the FRA often ignores its responsibility, as mandated by the Railroad Safety Act and the other major safety laws, to impose stiff penalties on carriers. In 1986, in fact, $10 was the average penalty imposed by the FRA for all safety defects by carriers discovered by FRA inspectors.

Railroad employees accept their responsibilities and the safety-sensitive nature of their duties, but until the FRA implements a regulatory program that gives carriers incentives to maintain a safer operating environment, death and injury rates on America's railroads will remain high and there may be more accidents like the Chase, Md., wreck.

RICHARD I. KILROY

Chairman, Railway Labor Executives' Association

Washington